- 8 - percent shareholder and ultimate decision maker) often served as a 1-percent or less general partner of the partnership. The two lease strip deals involve computer and photo processing equipment subject to two existing end-user leases. One end-user lease agreement, dated October 26, 1989 (hereinafter for convenience referred to as the K-Mart end-user lease or K- Mart lease), involved the lease of existing and after-acquired photo processing equipment by Varilease Corp. (Varilease) to K- Mart Corp. (K-Mart). On January 22, 1992, Computer Leasing, Inc. (CLI), purchased the equipment subject to the K-Mart lease along with Varilease’s rights and obligations under the lease. On May 18, 1994, additional equipment was added to the K-Mart end-user lease. The other end-user lease agreement dated July 1, 1993 (hereinafter for convenience referred to as the Shared end-user lease or Shared lease), involved the lease of computer equipment by CLI to Shared Medical System Corp. (Shared). Starting with the K-Mart and Shared end-user leases and certain other equipment leases with three other end users, a series of preconceived transactions was arranged with respect to that equipment. The transactions were intended to create residual lease periods beginning after the conclusion of the existing end-user leases with K-Mart, Shared, and the other end users. The transactions served as a foundation for two lease strip deals under which the rental income streams from thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011